TO: Federal Aviation Administration Office ofthe Chief Counsel 800 Independence Ave, S.W., 900 East Washington, D.C. 20591

1 .) PETITION FOR EXEMPTION FROM FEDERAL AVIATION REGULATION SECTION §63.39 (a) AND (b) (1}, (2}, (3} ALONG WITH THE THREE PHASE PRACTICAL TEST REQUIREMENT OUTLINED IN FAA-S-8081-21 WITH CHANGES 1, 2, AND 3 BASED ON MILITARY COMPETENCE 2.) PETITION FOR EXEMPTION FROM FEDERAL AVIATION REGULATION SECTION §61
.213 (a) (3} BASED ON MILITARY COMPETENCE
PETITIONER: 6TH AIR REFUELING SQUADRON FLIGHT ENGINEER SECTION 585 HICKAM AVE BLDG : 181 TRAVIS AFB, CALIFORNIA 94535 Primary POC: MSgt John McCarty Work: 707-424-7608 Cell: 707-853-6607 Email : john
. mccarty. 1@us
.af
. mil Secondary POC: SSgt Alex D. Reynolds Work: 707-424-7608 Cell: 813-389-5882 Email : alex.reynolds
. 1@us.af.milPETITION FOR EXEMPTION The U.S Air Force KC-1 0 flight engineer community seek an exemption from Title 14 C.F.R Section §63.39 (a) and (b), (1), (2), and (3) along with the three phasepractical testrequirement outlined in FAA-S-8081-21 with Changes 1, 2, and 3 based on military competence for a person who is a military flight engineer or former military flight engineer ofthe U.S. Armed Forces. This petition seeks to request an evaluation ofAirForce flight engineer training courses leading to certification as a military flight engineerusing the established standards for the civilian sector to the extentnecessaryto allow current andformer members meeting the requirements of sections §63.31, §63.33 (a), §63.35, and §63 .37 alongwith supporting documents determined by the administrator to be granted a Federal Aviation Administration Flight Engineer Certificate withthe appropriate aircraft ratingbased on military competence specificmission design series (MDS). The above petition serves to mirrorthe current standards set forth in § 61.73 Military pilots or former military pilots: Special rules. The U.S AirForce KC-10 Instructor flight engineer community also seeks an exemption from Title 14 C.F.R Section§ 61.213 (a) (3) based on military competence for a person who is a U.S military instructor flight engineerorU.S military flight engineer evaluator or a former instructor flight engineer or evaluator flight engineer. This exemption would allow current and former members meetingthe requirements ofsections §61.213 (a) (1), (2), and (4) as appropriate along with supporting documents determined by the administrator to be granted a Federal Aviation Administration Ground Instructor Certificate based on military competence. The above petition serves to mirrorthe current standards set forth in §61.73 (g) Militarypilots or former military pilots: Special rules.The members ofKC-10 flight engineer community are confident that theyhave met and exceeded the training standards outlined in the applicable C.F.R I P.T.S specifically §63.39 (a) and (b) (1), (2), and (3) and FAA
-S-8081-21 with Changes 1, 2, and 3 expanded task areas for flight engineers and§ 61.213 (a) (3) for ground instructors (Fundamental ofInstructing) by attending the following Air Force training courses: Aircrew Fundamentals- Flight Engineer w/Physiological Training, Basic Flight Engineer-Undergraduate FlyingTraining, KC
- 10 Flight Engineer Basic Pre-Qualification, KC
- 10 Flight Engineer Initial Qualification (Phase 1A and 1 B), KC-1 0 Flight Engineer Mission Qualification/ Mission Certification Training, KC-10 Continuation Training, KC-1 0 Academic Instructor Course, Flight Engineer Instructor CoursePhase 1A, and Instructor Flight Engineer Qualification

- Phase lB. Members would also be required to present a passingknowledge testreport for flight engineers based on§ 63.35 (a) (b) and for ground instructors based on § 61. 213 (a) (4) as appropriate for the rating sought. The knowledge test report would not exceed 24 calendar months sincebeing valid. Please see documents provided for a completebreakdown ofeach training curriculum in regards to the exemptions sought. This petition serves to recognize the hard work and dedication ofour flight engineer service members who have underwentmonths ofintensive Air Forcetraining and who possess comparable knowledge and skills as defined bythe administrator in the various documents appropriate to the certificate sought. This would be ofbenefit to thepublic as those individuals who have completed military flight engineer training courses would have their credentials evaluated using the same criteria found in the civilian sector. Also byusing the established standards applicable to the civilian sector, the administrator could be confident that safety would notbejeopardized. Unlike militarypilots who have a separate competence examinations tailoredto their situation, the current FAAwritten test administered to the civilian sector would suffice for military flight engineer and instructor flight engineer or evaluator's wanting to take the written test to demonstrate theirrespectively knowledge skill areas of63.35 (a) (b) and 61.213 (a) (4) as applicable. Furthermore this would motivate enlisted aircrew veterans to continue with a career in aviation after the military, thus using theirknowledge to strengthen training and operational standards throughout the aviation industrythereby givingback to the public sector. An exception to the current Code ofFederal Regulation being sought would not degrade current orfuture aviation safety standards as Air force flight engineer areheld to very high standards of initial and continuation training. Theintent ofthis petition does not serve to lessen the standards set forth in current directives, as member would still berequired to accomplish the written test for both flight engineer and ground instructor (aeronautical knowledge areas) and meet or exceed the passing score of70% . Furthermore current and former flight engineermembers seekingto utilize this exception to satisfy the flight engineerrequirements would have to show recent experience within the previous 12 calendarmonths. Ifnot they wouldberequired to complete a written and flight test appropriate to the rating sought. We are continually evaluated through a periodic evaluation system, mandatory annual check-rides annotated on AF Form 8 and are required to complete quarterlyrefresher training on emergency and abnormal procedures, aircraft systems, and CRM as a basic crew employing two pilots and a flight engineer in order to remain current and qualified to performed military flight engineer duties. This training is completed over a period oftwo days with each day comprising ofa two hours ofacademics followed byfour hours in a full motion simulator where emergency and abnormal procedures are expected to be accomplished at a proficient level. Members meeting the requirements ofthis petition and the administrator final rule would be able to provide evidentiary document showing theyhave notbeen removed from flying status for lack ofproficiency orbecause ofdisciplinary action involving aircraft operations. Ofparticularnote is the hardship in finding a current and qualified FAAflight engineer examiner or designated representative to complete thepractical portion of the flight check. Please note that the documents provided do not represent the entire Air Force flight engineer training curriculum and as such this petition is only applicable to turbojet powered aircraft class rating specific to the KC-10. On thebehalfofthe U.S AirForce KC-10 Flight Engineer's, we are grateful to administrator for considering this exemption and look forward to a favorable rulemaking on this petition. Please forward any additional questions or concerns to Master Sergeant John McCarty or StaffSergeant Alex Reynolds via the telephone numbers or emails listed above. Thanks. Very Respectfully,



# X John McCa , MSgt, USAF KC- 10A Flight Engineer

Alex D. Reynolds, SSgt, USAF KC-10A Flight Engineer